Munich, Germany

Regulation on sustainability-related disclosure requirements

“Regulation (EU) 2019/2088 on sustainability-related disclosure requirements for financial service providers” (Transparency regulation – TVO)

Some guidance on how to consider sustainability risks when advising on financial investment products.

Article 3 Transparency regulation (transparency in strategies for dealing with sustainability risks)

Within the context of selecting insurance companies and insurance products, we take into account the information provided by the insurers.
We may not offer insurers that recognizably do not include a strategy for incorporating sustainability risks in their investment decisions.

As part of the tailored advice provided in the customer’s interest, we explain separately if the consideration of sustainability risks in the investment decision means recognizable advantages or disadvantages for the individual customer.

The respective insurer informs about the respective consideration of sustainability risks in investment decisions with its pre-contractual information.

If the customer has any questions in this regard, they are welcome to contact us in advance of a possible conclusion.

Article 4 para. 5 Transparency regulation (adverse sustainability impacts at company level)

As part of the consultation, the most significant adverse impacts of investment decisions on sustainability factors of financial market participants (insurers) are taken into account. The consideration is based on the information provided by the insurance companies. The intermediary is not responsible for its accuracy.

At the moment, a consideration can only take place conditionally, due to information from the insurers about their companies, which is building up, but is currently still rudimentary.

Article 5 para. 5 Transparency regulation (transparency of remuneration policy in connection with the consideration of sustainability risks)

Remuneration for the brokerage of insurance policies is not based on the sustainability risks associated with their investments. This means in particular that the remuneration level of the product is not dependent on the sustainability risks of the investment.

Article 6 para. 2 Transparency regulation (transparency in the consideration of sustainability risks)

When advising on insurance investment products, Riester and basic pensions or occupational pension schemes, sustainability risks are included by using the pre-contractual information provided by the insurers.

In the event of a possible dutiful assessment of a comparable or better return on the product that takes sustainability risks into account, this product is recommended as a priority.